Justia Criminal Law Opinion Summaries

Articles Posted in Connecticut Supreme Court
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The Supreme Court affirmed the judgment of the Appellate Court affirming the judgment of conviction of felony murder, attempt to commit robbery, and other offenses, holding that Defendant was not harmed when the State, after granting immunity to three witnesses for testimony given during the State's case-in-chief, revoked that immunity when the same witnesses later testified in the defense case-in-chief. On appeal, Defendant argued that his constitutional rights to due process, a fair trial compulsory process, and to present a defense were violated when the trial court improperly permitted the State to revoke the immunity of the three witnesses at issue in this case, causing them to invoke their Fifth Amendment right against self-incrimination. The Supreme Court affirmed, holding (1) Defendant failed to establish that, by revoking the witnesses' immunity, the State violated Defendant's constitutional rights; and (2) there was no other prejudicial error. View "State v. Collymore" on Justia Law

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The Supreme Court affirmed the judgment of the appellate court affirming Defendant's conviction of conspiracy to commit robbery in the first degree, holding that there was no clear, obvious or indisputable error warranting reversal of Defendant's conviction. On appeal, Defendant argued that the trial court failed to instruct the jury on an essential element of the crime, as required by State v. Pond, 50 A.30 950 (Conn. 2012). The appellate court held that there was no obvious or undebatable error in the jury instructions and that, even if the instructions were erroneous, there was no manifest injustice necessitating reversal of the conviction. The Supreme Court affirmed, holding that the trial court's jury instructions were sufficient to guide the jury in arriving at its verdict. View "State v. Blaine" on Justia Law

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The Supreme Court affirmed the judgment of the Appellate Court concluding that the record was inadequate to review Defendant's challenge under Batson v. Kentucky, 476 U.S. 79 (1986), to the prosecutor's exercise of a peremptory challenge on a prospective juror, holding that the trial court did not commit clear error in finding that the prosecutor did not engage in purposeful discrimination when he peremptorily challenged the juror. Defendant was convicted of assault in the first degree as an accessory and conspiracy to commit assault in the first degree. On appeal, Defendant challenged the prosecutor's exercise of a peremptory challenge on a prospective juror on the basis of his employment history. The record, however, did not indicate the race or ethnicity of both the prospective juror and one of the two jurors whom Defendant pinpointed as examples of disparate treatment by the prosecutor. The Appellate Court affirmed. The Supreme Court affirmed, holding that the Appellate Court's well reasoned opinion fully addressed and properly resolved the certified issue. View "State v. Raynor" on Justia Law

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The Supreme Court affirmed the judgment of the Appellate Court upholding Defendant's conviction of felony murder on the basis of its rejection of his claim brought under Batson v. Kentucky, 476 U.S. 79 (1986), holding that that the Appellate Court properly affirmed the judgment of conviction but systemic concerns about Batson's failure to address the effects of implicit bias and disparate impact must be referred to a Jury Selection Task Force. Defendant was convicted of felony murder. The Appellate Division affirmed, holding (1) there was no adequate claim that the Appellate Court improperly upheld the trial court's finding that the prosecutor's reasons were not pretextual under the third step of Batson; and (2) although the relief the Court could provide was constrained by Defendant's decision to limit his Batson claims to the Equal Protection Clause, the broader themes of disparate impact and implicit bias that Defendant advanced raised enough concern with the fairness of the criminal justice system for measures to be concerned intended to promote the selection of diverse jury panels in the state's courthouses. View "State v. Holmes" on Justia Law

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The Supreme Court affirmed the judgment of the Appellate Court affirming the trial court's judgment rendered in favor of Defendant after the jury found that, although Defendant had perpetrated an intentional assault and battery on Plaintiff, his use of physical force was justified, holding that the trial court improperly instructed the jury, but the error was harmless. Specifically, the jury found that because Plaintiff was trespassing at the time of the incident and Defendant was acting in the defense of others, Defendant's use of physical force against Plaintiff was justified. The Supreme Court affirmed, holding (1) the trial court improperly instructed the jury on criminal trespass and defense of premises, but the improper jury instruction was harmless because the evidence was sufficient to support the jury's independent finding with respect to the special defense of defense of others; and (2) the evidence was sufficient to support the jury's finding that Defendant was acting in defense of others when he used physical force against Plaintiff. View "Burke v. Mesniaeff" on Justia Law

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The Supreme Court reversed the judgment of the habeas court denying Petitioner's successive petition for a writ of habeas corpus, holding that the State's failure to correct certain testimony deprived Petitioner of a new trial. Petitioner was convicted of felony murder. In his second habeas petition, Petitioner alleged, inter alia, that the State deprived him of a fair trial in violation of Brady v. Maryland, 373 U.S. 83 (1963), because the prosecutor failed to correct testimony of the then director of the state police forensic laboratory concerning a red substance on a towel found in the victim's home that, according to the director, had tested positive for blood. The habeas court rejected all of Petitioner's claims, despite the fact that no such test had been conducted and that a subsequent test of the substance proved negative for blood. The Supreme Court reversed, holding that the State's failure to alert the trial court and Petitioner that the director's testimony was incorrect deprived Petitioner of a fair trial. View "Birch v. Commissioner of Correction" on Justia Law

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The Supreme Court reversed the judgment of the habeas court denying Petitioner's successive petition for a writ of habeas corpus, holding that the State's failure to correct certain testimony deprived Petitioner of a new trial. Petitioner was convicted of felony murder. In his second habeas petition, Petitioner alleged, inter alia, that the State deprived him of a fair trial in violation of Brady v. Maryland, 373 U.S. 83 (1963), because the prosecutor failed to correct testimony of the then director of the state police forensic laboratory concerning a red substance on a towel found in the victim's home that, according to the director, had tested positive for blood. The habeas court rejected all of Petitioner's claims, despite the fact that no such test had been conducted and that a subsequent test of the substance proved negative for blood. The Supreme Court reversed, holding that the State's failure to alert the trial court and Petitioner that the director's testimony was incorrect deprived Petitioner of a fair trial. View "Henning v. Commissioner of Correction" on Justia Law

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The Supreme Court affirmed the judgment of the Appellate Court affirming the judgment of the trial court denying Defendant's motion to suppress evidence of a firearm that police seized during an investigatory stop, holding that the patdown of Defendant was supported by reasonable and articulable suspicion. Defendant entered a conditional plea of solo contenders to one count of carrying a pistol without a permit and one count of criminal possession of a pistol or revolver. The Appellate Court affirmed the judgment of the trial court denying Defendant's motion to suppress, holding that the trial court properly concluded that the patdown of Defendant was supported by reasonable and articulable suspicion that he might be dangerous. The Supreme Court affirmed, holding that the Appellate Court correctly concluded that the trial court properly determined that the patdown of Defendant was lawful under both the federal and state constitutions. View "State v. Lewis" on Justia Law

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The Supreme Court affirmed the judgment of the habeas court denying Petitioner's second petition for a writ of habeas corpus challenging his 1998 murder conviction, holding that the habeas court properly denied the petition. Specifically, the Court held (1) the habeas court correctly concluded that Petitioner failed to establish that he was actually innocent of the murder; (2) the habeas court properly determined that the identification procedures employed in this criminal case did not violate Petitioner's due process rights; (3) the habeas court correctly concluded Petitioner's first habeas counsel did not provide ineffective assistance of counsel; and (4) assuming, for the sake of argument, that the habeas court should have resolved Petitioner's cruel and unusual claims on the merits, Petitioner could not prevail on those claims, and therefore, it need to be determined whether the habeas court improperly applied the doctrine of res judicata. View "Bowens v. Commissioner of Correction" on Justia Law

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The Supreme Court affirmed the judgment of the habeas court rendering judgment against Petitioner, a juvenile offender, on his claim that the evolution of Connecticut's "standards of decency" regarding acceptable punishments for children who engage in criminal conduct has rendered the transfer of his case to the regular criminal docket and resultant sentencing unconstitutional, holding that Petitioner was not entitled to relief on his claims. Petitioner, who was fourteen years old when he committed felony murder, argued that his sentence as an adult after his case was automatically transferred to the regular criminal docket violated the state prohibition against cruel and unusual punishment. The habeas court denied relief. The Supreme Court affirmed, holding (1) transferring the case of a fourteen year old defendant to the regular criminal docket comports with evolving standards of decency and, therefore, does not violate the Connecticut constitution; and (2) Petitioner's forty year sentence does not violate the constitutional prohibition against cruel and unusual punishment after the provisions of P.A. 15-84 made Petitioner eligible for parole after serving sixty percent of his original sentence. View "Griffin v. Commissioner of Correction" on Justia Law